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June 11, 2014
NHeLP Comments on Provider Non-Discrimination RFI
Deborah Reid and Wayne Turner Comments
Section 2706(a) of the Affordable Care Act prohibits all group health plans and health insurance issuers offering group or individual health insurance coverage from discriminating with respect to participation under the plan or coverage against any health care provider who is acting within the scope of that provider's license…
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April 29, 2014
Re: California’s Bridge to Reform Demonstration (No. 11-W-00193/9)
Andy DiAntonio Comments
There are three major components of the CCI. As drafted, the amendment repeatedly fails to effectively delineate what changes are occurring under each of these separate components. The amendment frequently conflates the three components of the CCI, muddling an already complicated set of changes. The amendment should set forth,…
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April 29, 2014
Comments on All Plan Letter: Continuity of Care: Definition and Practice
Andy DiAntonio Comments
With the transition of seniors and persons with disabilities (SPDs) into managed care in 2011, we learned that COC is arguably the most critical factor in successfully transitioning high need beneficiaries into a new health care setting. The poor performance of COC protections led to significant, and at times…
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April 29, 2014
Comments on the Proposed Enrollment Strategy into Cal MediConnect for LA
Andy DiAntonio Comments
Approximately 216,000 dual eligible beneficiaries will receive multiple notices regarding enrollment into Cal MediConnect. Many thousands more will receive notices about enrollment in Medi-Cal managed care only under the Coordinated Care Initiative (CCI). In addition to the sheer number of impacted beneficiaries in LA County, the enrollment strategy also…
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April 29, 2014
Comments on Cal MediConnect Enrollment Materials
Andy DiAntonio Comments
The Coordinated Care Initiative encompasses several very complex changes. This makes it very difficult to create notices that can simply and concisely explain the changes in a manner that is understandable for the large number of beneficiaries impacted. At a minimum, the notices should: alert the reader to the…
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April 28, 2014
Comments on All Plan Letter: Continuity of Care
Andy DiAntonio Comments
We are happy to see that the APL addresses that COC applies to both continuity of services and continuity of provider relationships. However, we believe that the APL should be clearer and more definitive with regard to these protections. We have highlighted in the APL where language should be…
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